Date:    4/15/99 4:07 PM
     
     
Jonathan Katz
Secretary
Securities and Exchange Commission
450 Fifth Street N.W.
Washington D.C. 20549-0609
     
Re: Rulemaking for EDGAR System
File Number S7-9-99
     
     
Dear Mr. Katz,
     
        As a level one subscriber, Global Securities Information (GSI) welcomes
the modernization of the EDGAR system and applauds the SEC on accepting 
required SEC filings in HTML or SGML with unofficial PDF attachments. The 
overall idea of moving forward with a modernization plan after nearly five 
years of little or no change is a necessity for the investing public to reap 
the benefits of technological changes that have happened since the last changes 
to the EDGAR System.  However, we have a number of concerns.
     
Currently, the Commission is very explicit about what constitutes the contents 
of a EDGAR filing: it is everything between the <TEXT> and the </TEXT> tags. 
However, with the advent of HTML this distinction is blurred. The HTML format 
allows a filer to put information into a filing that will not be visible to a 
typical user using a web browser. In addition to creating a legal ambiguity, 
this situation creates uncertainty for people who view documents using software 
other than a typical web browser.
     
Since the proposed rule currently requires that HTML submissions be viewable in 
Internet Explorer 3.0 or greater or Netscape 3.0 or greater, the logical 
extension would be for the Commission to take the position that the official 
portion of an HTML submission is only that portion which actually is viewable 
using those browsers.
     
Such a position would mean that information contained in tags such as <!-->, 
<ISINDEX>, <BASE>, <LINK>, <META> would not be considered part of the official 
portion of the submission. Our conversations with the SEC staff indicate that 
there is no intention for those tags to be used for any meaningful purpose by 
filers, and that the only reason they are allowed in the proposed rule is so 
that filers will not be burdened by having to remove them. 
     
A secondary recommendation would be for the disseminator to remove these 
meaningless tags from submissions before they are passed on to feed 
subscribers. This would be consistent with current practice, where tags such as 
<R>, </R>, <SEGMENTS>, </SEGMENTS>, <MODULE>, </MODULE> are removed from 
submissions before the submissions are disseminated.
     
        GSI requests that Rule 310 Marking Changed Material be available to the
public. First, many of the writers of SEC Filings (corporate attorneys) do 
document comparisons in various write programs to show the changes that have 
been made to previous documents. Second, the Commission currently allows 
outside parties to FOIA this material as well as the comments the commission 
makes on these documents. Third, allowing the individuals who write this 
material to have immediate access to changes will expedite the process of 
review therefore saving the SEC time and manpower which would allow them to 
review more filings. 
     
        GSI would also support a more rapid phase-in of currently Non-EDGAR
filings that are made at the Commission, as these Non-EDGAR documents are very 
useful to the investing public. Examples are as follows: BD's, ADV's and 
certain foreign filings. Currently these forms are posted on the SEC WKLD, many 
times not available in the SEC public reference room at the regulated price, 
but through the contractor at the non-regulated price, which is many times the 
rate charged in the SEC Public Reference room. (We have spoken to Ken Fogash 
and Shirley Slocum however the situation has not changed). A rapid phase-in of 
these documents as well as 3's, 4's, 5's and 144'S would deliver a 
multi-pronged benefit to the Commission and the investing public. The 
Commission would reduce overhead on the processing of tens of  thousands of 
documents; the investing public would have faster access to insider information 
and vital information about their Broker Dealer and Investment Advisors; and 
Primary Users would stop complaining about unfair competition due to early 
release of documents to the contractor and no one else(probably the best reason 
for the change).
     
     
Sincerely,
     
     
     
     
Phillip Brown
Managing Director
Global Securities Information
     
     
     
Holden