From: MARIA ISABEL S. VIEIRA [isabel.vieira@csn.com.br]
Sent: Monday, December 03, 2001 8:04 AM
To: 'rule-comments@sec.gov'
Subject: EDGAR

Dear Sirs,

Whereas Securities and Exchange Commission ("SEC") proposed to amend its
rules in order to require foreign private issues to file their SEC documents
electronically through its Electronic Data Gathering, Analysis and Retrieval
("EDGAR") system;

Whereas the proposed amendment seeks to (i) facilitate the rapid
dissemination of financial and business information about foreign issues;
(ii) place non-U.S. issuers on equal footing with U.S. issues; (iii)
increase market exposure for non-U.S. issuers;

Whereas Companhia Siderúrgica Nacional is a reporting company since
November, 1997;

We would like to suggest the following:

(i) Non-U.S. private issuers should not be required to submit its annual
report exhibit in Form 6-K through EDGAR, since all financial statements
included in the annual report will already be submitted electronically
through a previous 6-K Form as well as the 20-F Form. Furthermore, CSN as
many other foreign issuers, discloses its annual report in its website;  

(ii) Foreign issuers' statutory reports should be permitted but not required
to be submitted electronically. We view them as not essential for analysis
by the investor community. 

(iii) Non-U.S. private issues should continue to submit in paper form some
documents filed under cover of Form 6-K, such as formatted statutory reports
prepared for Brazilian Securities Exchange Commission and presentations for
analysts, and a and a summary of the document or its respective press
release should be filed through EDGAR

(iv) Rule 306 should permit, in line with paper filing rules, that foreign
issuers continue to file their exhibits to registration statements or
reports in a foreign language but accompanied by a summary in the English
language. We view that this change would facilitate the reading of exhibits,
since making them shorter, as well as providing non-U.S. private issuers
with significant translation cost reductions.

(v) The amendments to Regulation S-T should become effective for filings
made six months from their date of adoption, in replacement of the
four-month proposed transition period. We consider four months a too short
period for foreign issuers to get familiar to the Commission's rules and
procedures regarding EDGAR as well as to train their employees to the new
filing system; 

(vi) In order to avoid any delay in the filings, instead of a written
certificate, signed by an officer of the company, in which he certifies the
fairness of the translation of the document filed electronically, non-U.S.
private issues should execute a general certificate stating that all English
translations of the documents  filed electronically will be fair and
accurate.

Sincerely,

Maria Isabel dos Santos Vieira
Senior Legal Counsel


Monique Padilha de Freitas
Investor Relations Specialist