Global Securities Information
419-7th Street NW
Washington, DC 20004

February 22, 2001

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450-5th Street NW
Washington, D.C. 20549-0609

RE: File No. S7-02-01 Intended Modifications to an Existing System of Records: Establishment of a New System of Records

Dear Mr. Katz:

Global Securities Information, Inc. (GSI) specializes in providing research and real time dissemination of vital corporate information released by the Securities and Exchange Commission and other Government organizations overseeing the financial markets. GSI appreciates the opportunity to comment on intended modifications to the existing system of records and the establishment of a new system of records.

The amendments that were put into effect with the development of the new Investment Adviser Registration Depository (IARD) system require investment advisors to submit all Form ADV applications for registration, Form ADV amendments, and Form ADV-W withdrawal requests electronically through IARD. In effect, this makes NASDR custodian of investment adviser registration records filed electronically. The IARD system was to be functional and in place months ago. This inability to deliver in a timely manner leads us to believe that the Commission should retain guardianship and distribution rights to the data. It also leads us to question just who owns the system, and under what portion of the '34 Act mandate the dissemination of this data falls under.

This is public information yet counter requests at the SEC Reference Room are completed within 10-15 business days, as well as limits on the number of requests per day. This data is to be filed electronically and we therefore believe that as with EDGAR filings the public is entitled to the same timeliness of access. It appears that there is no provision for the purchase of a feed as there is for the EDGAR Database. As a service bureau we believe that the IARD system should be available under the same terms and conditions as the EDGAR Database.

Thank you for the opportunity to comment on the proposed change. If you have any questions regarding the above comments, please contact me at 202 628 1155, extension 3216 or via e-mail at


Debra F Strahan
Global Securities Information, Inc