March 24, 2000
Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 Fifth Street N.W.
Washington, DC 20549-0609
Re: File # S7-05-00
Dear Mr. Katz:
These comments are on behalf of Internet Financial Network, Inc., ("IFN") a Level One EDGAR redistributor, regarding the Proposed Rulemaking for the EDGAR system.
- Given that the Commission is solicitng comments at this late date in relation to the proposed release 7.0, IFN recommends that the release date be postponed to no less than 90 days after the comments have been compiled and acted upon.
- IFN questions why the Commission is proposing to eliminate the requirement for filers to g commensurate way to compare filers. IFN not only thinks the FDS Exhibit should remain, but also that it should become an attached Excel or Lotus worksheet (as should be all financial tables within a filing. Excel and Lotus together comprise the vast majority of spreadsheet users.
- IFN is concerned, as is the Commission, regarding the increased size of filings now that filers will be encouraged to provide html files and such files may be laden with graphics and images. IFN now stores over 60 gigabytes per year, most of which is in compressed format, not including the gigabytes of plain text indices also archived for these filings. This not only affects Level One providers like ourselves, but also the www.sec.gov EDGAR archive, which will experience similar storage and user access problems.
While we may not have the perfect solution, we would suggest that the Commission require that filers limit charts and other graphics to depictions of otherwise required content. This might include five year trend-lines or pie charts that breakout revenue segments. It would not, however, include pictorial displays often found in annual reports. IFN recommends that companies be permitted to hypertext reference their own web sites from the filings for such pictures or graphics that do not specifically relate to required information.
- Since so many EDGAR users rely on Level One data providers like IFN for EDGAR information, having companies reference via a hypertext link previous filings at www.sec.gov will become confusing. One minute the user will be at our fileserver accessing a document, the next he will be hpertexted away to the sec.gov site. A better solution might be to have the filer simply link to a file accession number, which should be indexed in some manner by all EDGAR providers.
- Regarding PDF copies, which the Commission has stated are unofficial copies of filings, IFN believes the inclusion of such unofficial copies will create an inordinate amount of additional storage requirements, both for Level One providers and for www.sec.gov. Especially since these pdf documents are unofficial, why not let the filer link back to its own site and server for the pdf download.
- For similar storage reasons, unless multimedia files such as streaming video or audio become official, required filings, IFN recommends that the Commission and the Level One providers not take on the burden of archiving such voluminous files. Rather, allow the filer to link to its own site for multi-media downloads.
- For reasons previously mentioned, IFN does not think it wise for companies to submit documents composed of multiple linked HTML files. We do not understand how the filer can place relative links within files that will reside on a Level One provider's server.
- IFN does not object to hypertext links within the same filing but if the filing now consists of several documents instead of a single lengthy document with Exhibits, then somehow all the documents must be chained together. Perhaps that can be accomplished by assigning parent child accession numbers, but that may complicate indexing even further.
- We agree that filers should not be able to use hyperlinks to satisfy disclosure requirements.
- Hyperlinking from one filing to another becomes difficult unless the filer references some relative file number (the accession number) of the previous filing. This becomes difficult to handle in a hypertext environment.
- IFN agrees that EDGAR submissions should be free of executable code regardless of the format of the filing.
- We welcome the addition of Forms 3,4,5 and 144 as mandatory electronic filings.
- IFN welcomes the switchover from SGML to XML tagging. Presumably the Commission will set a standard of XML tags to be used in the header and/or body of the document .
- As mentioned earlier, we recommend the use of external links (to filer's servers) for unofficial pdf documents as well as audio and video files and pictorial displays such as full color annual reports.