From: Quinlivan, Stephen [stephen.quinlivan@leonard.com]
Sent: Tuesday, November 13, 2001 1:27 PM
To: SEC Comments (E-mail)
Subject: S7-18-01

To: 	Jonathan G. Katz
	Secretary
	U.S. Securities and Exchange Commission
	450 Fifth Street NW
	Washington DC 20549-0609

Re:  Comments on Proposed Rules Mandating EDGAR  Filings by Foreign Private
Issuers

My name is Steve Quinlivan and I am a practicing securities lawyer, and the
views expressed herein are my own and not those of any firm or client.  I
support the amendments to the rules mandating electronic filing for foreign
private issuers.  In my view, the technological burdens have lessened since
the EDGAR rules were adopted, and it is essential to have electronic access
to all disclosure documents with respect to issuers accessing the public
capital markets.

Specifically:

--Both foreign private issuers and foreign governments should be mandated to
make public filings.  There is no reasoned policy reason calling for a
different result.

--6-Ks including annual reports should be required to be filed
electronically.  The annual report is an essential disclosure document that
should be publically available.

--Form CB should be required to be filed electronically when an Exchange Act
reporting company is involved.  That is when the market needs the
information the fastest.

--Rule 12g3-2(b) applications and supporting documents should be required to
be submitted in EDGAR.  Analysts and other issuers have an interest in being
able to easily track such data and submissions.

In closing, I believe the Commission should continue to consider whether
differences in disclosure and reporting requirements between US and foreign
private issuers continues to be warranted.



Steve Quinlivan