From: Mike Mostransky [mike.mostransky@burrups.com]
Sent: Monday, October 29, 2001 12:58 PM
To: 'rule-comments@sec.gov'
Subject: ref File No. S7-18-01 :EDGAR & Foreign Issuers

To Whom it May Concern:

As an International Financial Printer and Filing Agent we will be
experiencing the mandating of the requirement of Foreign Issuers to file
Edgar.  One issue that I would like to address regarding the current
proposal is section C: Electronic Filing Hours.  I would like to make the
recommendation that the SEC re-evaluates their current position on the
electronic hours of operation for Edgar Filing.  It is our thought that if
the SEC were to offer the ability to transmit EDGAR filings via
https://www.EDGARFiling.sec.gov from 8:00am GMT (3:00am EST) to 10:00pm GMT
(5:00pm EST) it would help our filing department greatly.

I don't see that the SEC would have to offer any technical support prior to
8:00am EST (1:00pm GMT) however the ability to test and live file documents
would help in relations to clients and workload.  In the past I have been
told that the SEC only allows the submission of filings from 8:00am EST to
10:00pm EST because the remainder of the time is needed for maintenance and
downtime.  I can't see why the additional 5 hours of "electronic" running
time couldn't be offered.

Regards,

Mike Mostransky
Technical Sales Executive
Burrups
020 7902 6298