Subject: File No. S7-05-00; Rulemaking for EDGAR System, #2

Date:    03/21/2000 5:24 PM
     
     
     
     
March 16, 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 continue requiring the 
filing of Financial Data Schedules (FDS) as exhibits to Form 10-K and 10-Q.
     
While the existing FDS is admittedly imperfect, it is the most nearly 
uniform of the disclosure documents currently required of public companies. 
It is the only place where investors can currently find financial 
information on a consistent basis, in a consistent format.
     
The elimination of the FDS will negatively impact the individual investor as 
their are a number of public access sites such as CNN FN, 10KWizard, 
Spredgar, and Edgarscan that allow the individual investors to look at a 
snapshot of a 
reporting company's financial health, at no cost, without reading through 
thousands of pages of financial information. 
     
If anything, we feel that the FDS items should be expanded for further 
clarity and completeness.  If done properly, individual investors would be 
able to summarize a public company's health quickly and accurately, as the 
1940 Act rules allow with summary prospectus information.  Less disclosure 
in this area is a step backward, not forward. 
     
The Financial Data Schedule represents the area of EDGAR where the 
Commission comes closest to its goal of providing uniform disclosure to the 
investing community.  Shortcomings in the existing process should be 
addressed by enhancing the FDS rather than eliminating it.
     
Sincerely, 
Nicholas B. Keenan
Chief Technology Officer
Global Securities Information, Inc.