Attachment_4_EDGAR_Submissions.doc

EDGAR Submission Structure EDGAR accepts electronically filed submissions for review and dissemination by the SEC. The submissions contain header information and a document or documents. The documents are created by word processing packages, distillers, software, and/or editors. The header information is created by EDGARLink On-line where filers enter header data into the SEC EDGAR web interface, or independently by third-party filing products. EDGARLink On-line and the third-party filing products create the submissions by merging the header information with the documents in an SEC defined structure. There are multiple submission structures currently accepted by the EDGAR system. Each of these structures consists of a submission header and a document or set of documents. The header and documents are delimited by tags as such:

<SUBMISSION>

<TYPE>

10-Q

<DOCUMENT-COUNT>

<SROS>

AMEX

<FILER>

<CIK>

9999999999

<CCC>

xxxxxxxx

</FILER>

<PERIOD>

06/30/1998

<DOCUMENT>

10-Q

<DESCRIPTION>

quarterly report

<TEXT>

The bulk of the

<TABLE>

document appears

</TABLE>

between text tags for a

</TEXT>

submission.

</DOCUMENT>

<DESCRIPTION>

<TEXT>

<TABLE>

</TABLE>

</TEXT>

</DOCUMENT>

</SUBMISSION>

More specific information on header tags and submission structures can be found in the EDGAR Filer Manual and technical specifications found on our website at www.sec.gov.

ASCII

One of oldest used data formats used in EDGAR filings is ASCII-based text combined with SGML-like tags. SGML-like tags are used sparingly inside the text of filings to assist with readability or processing.

Filers, most of whom create their filing document today in word processors, convert this original material to ASCII format and then manually edit the text to insert any required SGML markup tags inside the filing. The required header data and the document are combined in a file, called a submission. The combination of the header and document can be accomplished at the SEC filing website interface, called EDGARLink On-line; however, a number of third-party tools have been introduced to perform this function.

ASCII filings represent approximately 9% of documents currently filed on EDGAR.

HTML

As part of EDGAR’s modernization, which ended in 2001, the SEC added Hypertext Markup Language (HTML) as an official filing document structure. The SEC uses HTML version 4, but does not allow all of the tags of that standard set to be used. Filers create their HTML documents using the HTML authoring tool of their choice. JPEG and GIF files can be included in HTML filings.

Filers must still be able to create their submissions in their word processor or web authoring tool of choice. Charts, graphs, images, pictures and logos which were part of the original word processing file should carry forward into the HTML-based submission. The Filer Manual and rule-making provide valuable tools to guide the filer in this regard.

HTML filings represent approximately 49% of documents currently filed on EDGAR.

XML

The EDGAR system creates XML documents from submitted filer input on the OnlineForms website. It also accepts XML documents from third-party software products as outlined in our XML Specification.

XML filings represent approximately 42% of documents currently filed on EDGAR.

PDF

The Commission allows filers to submit PDF files as unofficial copies or as attachments to their filings depending on the rule. Unofficial copies of the primary document have no official status for any SEC regulatory purpose. PDF files that are attachments may have an official status, depending on the rule. Both unofficial PDF copies and PDF attachments are processed by EDGAR. They are accepted, stored, accessed by SEC staff through the EDGAR workstation application, and disseminated to the public (unless the processing rules determine otherwise).

Less than 1% of documents coming into EDGAR are PDF.

XBRL

In March, 2005, the SEC began accepting XBRL files as part of its XBRL Voluntary Filing Program for the disclosure process. Those XBRL documents were unofficial copies of the financial data that is required in an ASCII or HTML document. The SEC XBRL Voluntary Filing Program has become a mandatory filing paradigm where filers must file XBRL formatted documents to the SEC. At the present time, XBRL documents are received, stored, disseminated, and accessed by SEC staff as part of the EDGAR system.

XML filings represent approximately 2% of documents currently filed on EDGAR.

EDGAR Submission Traffic

The EDGAR system was not sized to handle the peak hour of traffic with no noticeable system degradation. Rather, it was sized to handle a reasonable amount of traffic and build wait queues for the overflow during peak hours. Traffic throughout the day is relatively light for the deployed capacity, however, the system is taxed on peak hours. The current trend is for many filers to submit their filings on the last hour of the last day that they are due. Below are some current traffic statistics:

· EDGAR supports 596 electronic and paper form types (373 electronic/paper form types, 148 paper-only form types, 20 electronic only form types, 4 CRD form types, 18 system form types, and 33 Not-Timely form types).

· The SEC receives and processes approximately 500 Gigabytes of data each year (the equivalent of 250 million pages of ASCII data). Of that 500 Gigabytes, 250 Gigabytes are indexed and stored in our storage arrays and disseminated to the public.

· The SEC disseminates approximately 125 million pages of LIVE data each year, which equates to about 250 Gigabytes of stored data. There is approximately another 250 Gigabytes of TEST data, which is archived to tape and not indexed or stored in the EDGAR database.

· Filing volumes are currently approximately 1,600,000 filings per year: 750,000 accepted filings plus 850,000 test and suspended submissions.

· The average filing size is 350,000 bytes (approximately 175 ASCII pages)

· HTML currently makes up over 49% of filing volume and on average an HTML document is three times the size of an ASCII document.

· The file size of the PDF “unofficial copy” typically equals that of the HTML file with its associated images.

· Less than 1 percent of all filings include a PDF copy

· The daily load on the system for a non-peak day is 3,500 live filings and 3,500 test filings.

· The peak day load on the system is 15,000 filings (live and test). The most filings received during a peak day is just under 21,000 filings.

· The peak hour load on the system is 1,500 filings. The most filings received during a peak hour is just under 3,400 filings.

· Filings cannot exceed 200 megabytes. The largest file on EDGAR is over 300 megabytes (filed before we started validating for file size).

· There are over 500,000 entities authorized to file on EDGAR.

Over the period of this contract, further changes to EDGAR’s official document structure are likely. It is also possible that the SEC may change the percentages of the current document structures that are received, stored, and disseminated by EDGAR. Document structure and design decisions affecting document structure implementation are critical to EDGAR’s ongoing success. It is imperative that any development work under the contract include software design that ensures applications and COTs products associated with document structure are minimally impacted and easily modified if changes in document structure are made.

ATTACHMENT 4