3 December 2001

Mr Jonathan G Katz      rule - comments @ sec.gov
Secretaries and Exchange Commission
450 Fifth Street N.W.
WASHINGTON D C 20549 0609

Proposed Rule: Mandated Edgar filing for Foreign Issuers
File No - S7-18-01

Dear Sir

This submission is presented on behalf of Australia and New Zealand Banking Group Limited ("ANZ"). ANZ currently has shares listed on the Australia and New Zealand stock exchanges and ADRs on the New York Stock Exchange.

ANZ fully supports initiatives to automate the filing, dissemination and analysis of financial information, however, we seek consideration to be given to 2 issues.

1. Use of HTML

EDGAR utilises HTML as the format for electronic filings. As an alternative ANZ requests that filings also be accepted in XBRL and PDF formats. In support of this submission, we advise as follows:

XBRL as one alternative

We believe that within a relatively short timeframe, Extensible Business Reporting Language ("XBRL") technology will become the standard for electronic filing and analysis.

XBRL provides financial reporters with a standards-based method to prepare, publish in a range of formats, reliably extract and automatically exchange financial reports of public companies and the information they contain. XBRL will benefit a wide variety of users of financial information, including analysts, investors, regulators, financial publishers and the companies who prepare the financial reports. XBRL technology is a generation on from the HTML technology used in EDGAR and has clear advantages.

We believe that XBRL will not only meet the SEC's current requirements but also enable more sophisticated and complete analysis of financial information than is possible using EDGAR.

ANZ is devoting resources in preparing to take full advantage of the benefits of XBRL for external and internal reporting. We would prefer not to incur the additional cost and management time of also implementing EDGAR as an interim measure. Therefore, before the proposed requirement for foreign organisation to make all filings through EDGAR is implemented, we would urge the SEC to fully consider to what extent and how quickly XBRL may impact on the future use of EDGAR.

  • PDF as another alternative

    Presently ANZ lodges announcements and financial results electronically with the Australian Stock Exchange in PDF.

    We understand that three Canadian exchanges and the London Stock Exchange all accept lodgements in PDF.

    2. Hours of Operation / Date of Filing

    We note the Commission accepts electronic registrations from 8.00 am to 10.00 pm US Eastern time. Electronic filings commencing after 5.30 pm are US Eastern time accepted as filed on the next business day.

    ANZ operates an Australian Eastern Standard time or Eastern Summer time which typically has a 16 to 17 hour time differential (dependent upon summer time adjustments) between New York and Melbourne.

    We suggest that the Commission permit unrestricted electronic lodgements in any 24 hour period.

    We would appreciate receiving a formal response to this submission in due course.

    Yours faithfully

    Peter J Mathews
    Assistant Company Secretary