Bernard E. Klein
3000 Stirling Road
Hollywood, FL 33021
954-981-8800 Fax 954-981-8800
June 13, 2002
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission email@example.com
450 Fifth Street, NW
Washington, DC 20549-0609
Re: Release 2002-88
Proposed New Form 8-K Disclosures and Filing Deadlines
Dear Mr. Katz:
Even before you post the Proposed Rule for New Form 8-K disclosures, I want to give input about the usability of EDGAR, which has to be part of the SEC's plan to make these filings useful to the investing public.
Even under current regulations, it is overwhelming for an investor to process the data on 8-K's. Daily, there are about 140 to 240 filings. There is no useful hint of the content, such as Change of Auditor, or any other sub-category. In the current system, an 8-K EDGAR filing does not include a labeled header field in the dissemination data. The searchable labeled fields are those listed on this page:
For the most part, the fields of the disseminated database are those common to all form types, plus filed-by/subject company information if applicable.
The SEC system "does not have the computing power to parse out the items from the text of all the 8-K filings," according to an email response I received June 11, 2002 from Ruth Pitt, of your Web Support group. In conjunction with the implementation of the new rules on 8-K filings, please consider at least a voluntary scheme to add a Header, perhaps a 3-letter code - such as COA for Change of Auditor - would not be "part" of the filing, for regulatory purposes. This would help an EDGAR reader to focus on the filings one is interested in, and to skip others.
One way to do this is to make it optional and let market forces work. A company could enter up to 40 (or 80) characters [whatever number the "next" EDGAR version allows] that could display on the EDGAR retrieval system. Those filers that want their filings read, may decide it's worth the extra effort to give a clue. To make this work, when reading filings, I'd like you to allow a user to set a preference to Show Comments (the default would Show Comments, but the reader could set it to Don't Show Comments). You'd get quick feedback on which display users want.
These days I need this feature for Current Filings, but I think it should be generally available.
/s/ Bernard E Klein
Bernard E Klein