Greetings Commission, I would be interested in seeing EDGAR undergo adjustments to make it more simple for issuers to file documentation accurately and on time without requiring third parties to manage file submission. For this proposal, I believe specifically the API access outlined in Rule 10(d)(3) is the most crucial item which should be added to the regulations. As a retail investor who is interested in issuers being able to focus more funds towards their own business and development rather than towards contracting specialists for file submissions and compliance. However, I do recognize that the established system does involve a lot of contracting and middlemen for successful and timely submission, and this would not change overnight. The Commission's proposed ideas (d1, d2 especially) will help bring more security to the current system. I had not realized until reviewing this proposal that current logins are assumed to be legitimate purely based off shared access to a single set of credentials. By adding another layer of authorized user accounts and allowing the issuer to control those accounts access more security can be introduced. In the vein of additional security, the proposal as written also currently suggests requiring monthly logins to maintain access to an API access code which is open for one year. I feel this could be considered heavyhanded in comparison to the fairly lax standards which exist today, but I do think it's worth the additional security and expectation from those submitting data. The most important thing to me is that machine to machine interfaces which take advantage of the EDGAR API are encouraged wherever possible. If there can be consistent data input thanks to access to the API, then we'll see more accurate and timely submissions of required filing documents. This will help not only issuers, but it will help the SEC to save time and resources and it will help the investing community who monitor filings to see more consistency in their format and content. In summary, I do feel that each element of the proposal is valid and a worthwhile step forward for a system which desperately needed it. My suggestion for improving the proposal is to provide the API on a wider scale. There is a robust secondary market which exists today seeking to monetize the submission of required filings through the legacy EDGAR system. Hypothetical - If the SEC chose to provide visibility into the required fields and formats which EDGAR accepted, there may be industrious altruists out there who seek to build submission software which would be easier to use for issuers. I see no reason to protect or enable the entrenched secondary market for data submission, and would prefer that issuers be able to cleanly and easily submit documents directly. Thanks