Comments re mandatory electronic filing via EdgarFrom: Fekete, Peter PF [Peter.F.Fekete@BHPBilliton.com]
Sent: Sunday, December 02, 2001 10:14 PM
To: 'rule-comments@sec.gov'
Cc: Taylor, Roger RV
Subject: Comments re mandatory electronic filing via Edgar

Dear SEC, 

Re your letter - SEC proposes to require electronic filing of registration and 
disclosure documents for ADR issuers, proposed new EDGAR rule for non-US issuers 
dated October 2001.

Presently we send you our filings electronically in HTML or text format with the
exception of our Annual Report which we send via post.

We find Edgar's format requirements ie: certain sub-set tags of HTML V3.2 and text 
very restrictive which causes alot of extra work for our larger documents eg: Qtr 
Profit report.

We would prefer the SEC to allow "PDF" documents sent as "official" filings & to 
be able to use the full set of HTML V3.2 tags.

Is the SEC making any allowances for Annual Reports ie: keep sending via post - as 
if this was to be converted to "text" there would be no images or formatting not to 
mention the work involved?

Thank you 
Peter Fekete - BHP Billiton Ltd Melbourne Australia 




EOM 

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