Command Financial Press Corporation
75 Varick Street
New York, NY 10013
212-274-0070
Fax: 212-274-8262
www.commandfinancial.com
     
     
March 27, 2000
     
Mr. Jonathan Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
     
Re: S7-05-00; Proposed Rules for EDGAR
     
Proposal to eliminate Financial Data Schedules

        Command Financial Press Corporation fully supports the proposal to
relieve filers of the requirement to prepare and submit FDSs and to remove 
the requirement for Financial Data Schedules from all rules and forms. While 
FDS data may be useful to the public, its primary purpose is to provide 
tagged financial information to the SEC staff. EDGAR modernization will 
afford the SEC staff access to this data through outside sources.

        Command Financial Press Corporation, in its capacity as a filing
agent, assists many filers in the creation and transmission of their 
filings. The requirement for FDSs constitutes a burden on filers and 
jeopardizes the timely filing of their documents. Improper use of FDS tags 
and syntax require "last-minute" correction of numerous errors. Often, no 
FDS at all is provided, again causing "last-minute" efforts to include an 
error-free FDS.

        Regarding Form N-SARs, Command recommends retaining the FDS
requirement for the time being, but removing the FDS requirement in future 
rulemaking and incorporating the FDS information into the Form N-SAR itself.
     
Proposal to allow graphic and image files in HTML file submissions

        Command Financial Press Corporation supports the proposed
"middle-ground" of allowing graphics only in limited instances where the 
rules require them.
     
Command Financial Press Corporation thanks the Commission for the 
opportunity to comment on the proposed rule changes. 
     
     
Sincerely,
     
Leonard Goldstein

Vice President, Technology