ICI Supports Proposed Changes to EDGAR System

Washington, DC, June 4, 2004 - The Institute recently filed a comment letter with the SEC supporting proposed amendments to electronic filings on the EDGAR system that would require mutual funds to identify each of their series or share classes in electronic filings.

Background
The proposed rules would require that certain open-end management investment companies identify in their EDGAR submissions information relating to their series and classes. In addition, the SEC proposes to add several investment company filings to an existing list that must be filed electronically and amends the rules governing the electronic submission of filings through EDGAR. These amendments are intended to keep EDGAR current technologically and make it more useful to the investing public and SEC staff. The proposed amendments would also require electronic filing of litigation materials and fidelity bonds via the EDGAR system.

ICI Position
The Institute supports the proposal to require series, share classes, and contract identifiers in electronic filings, stating in its comment letter that such a change would enable investors and others using the EDGAR system to easily search for and identify filings relating to a particular series, share class, or contract. The Institute also urges the SEC to permit, but not require, litigation materials to be filed electronically. The Institute states that litigation materials are typically received in paper form and that it will be difficult to convert them into electronic form and file them within the mandated ten-day time period. The Institute also makes several recommendations intended to ensure that electronic filings are not delayed or disrupted due to identifier-related problems.

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