March 20, 2000
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549
     
Re:  File No. S7-05-00; Rulemaking for EDGAR System
     
Global Securities Information urges the Commission to consider a phased 
introduction of new features to the EDGAR system.  Specifically, when 
changes are planned to the EDGAR system, we encourage the Commission to 
solicit the filing community for "beta-testers" who are interested in taking 
advantage of the new features, and restricting filings to that group until 
all issues with the new features are resolved.
     
Last year, when EDGAR 6.0 was released, the dissemination community was 
notified of changes approximately 30 days before the changes were scheduled 
to be released.  At that time, the SEC had no idea of how many filings would 
be released in the new format, or how many filers would take advantage of the 
new features, or who those filers were.  Feed recipients were provided with 
sample filings, but they were not meaningful as they had been prepared by TRW 
and were not representative of actual documents prepared by filers. Frankly, 
we were stunned to learn that the flow of EDGAR information, which the 
financial markets depend upon, was so cavalierly being threatened by this 
lack of forsight.
     
In the face of this lack of information, we felt that the only reasonable 
thing we could do to guarantee our subscribers an uninterrupted flow of 
documents was to have our entire operations and programming staffs in our 
operations room before 8 o'clock on the morning that the changes went into 
effect.  We were fortunate that the new features ended up being extremely 
unpopular with filers, and there was no interruption in the flow of 
information to our customers, but the disruption and expense to us was 
considerable.
     
This disruption and expense, which was felt to a certain degree by all feed 
recipients, could have been largely avoided.  If the SEC had formed a group 
of beta-testers, and required each one of them to submit a test filing with 
the new features before submitting an official filing with the new features, 
the dissemination community would have had a very good idea of what to 
expect.  This strategy mirrors the successful rollout of the original EDGAR 
system in 1993, which started with a small pilot group which was expanded as 
the system evolved.
     
Such a strategy would not have been difficult to implement.  To date, the 
changes in EDGAR 6.0 have been extremely unpopular with the filing 
community.  Only about 300 of the more than 40,000 EDGAR filers have taken 
advantage of those changes.  If those 300 filers had been asked to identify
themselves beforehand, much of the uncertainty and risk could have been avoided.
     
The EDGAR system has been extraordinarily successful, and it is now a vital 
part of the workings of the financial markets.  As such, it is now 
recklessly irresponsible to continue the "turn it on and see if it works" 
approach to changes in the system.  Global Securities Information, Inc., 
urges the Commission to mandate that future changes be implemented in a 
controlled and methodical manner.
     
     
Sincerely, 
Nicholas B. Keenan
Chief Technology Officer
Global Securities Information, Inc.