We have several concerns about the impact the proposed changes will have on our computing processes, the time and cost to retool these processes, and the impact it will have on our end-users. Additionally, we feel there are a significant number of critical issues that must be addressed in detail and in advance of implementation to avoid inflicting economic and logistical hardship on Filers, the SEC, Vendors, and the investing public. We noted over 27 specific requests for comment in your proposal. It appears that the driving force behind the proposed changes is one of aesthetics. The look and feel of current documents might be considered rather boring, lengthy and monotonous.
Filings tend to look legalistic and can be tedious to read.
Graphic designers and artists by trade have familiarity with HTML and it's various standards and incompatibilities. We are concerned that the SEC has underestimated it's own support requirements. On the contrary, filers must now become proficient in a computer mark-up language and must have a thorough understanding of which tags are allowed and which are not. HTML, a relatively new standard to the marketplace, is constantly evolving. Filers must have clear guidance and specifications on what is and is not acceptable.