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D.C. 20549

December 19,2014

The Honorable Tim Johnson

Committee on Banking. Housing and Urban Affairs
United States Senate

534 Dirksen Senate Office Building
DC 20510-6075
Dear Chairman Johnson:

Thank you for your November 3. 2014 letter regarding a recent academic study
suggesting that company filings submitted electronically to the Securities and Exchange
Commission may sometimes be available to private subscribers before the general public. I
share your concern about the importance of the SEC's management of data and the manner in
which we make company filings available to the general public.

As background, when Congress originally authorized funds to establish the Electronic
Data Gathering, Analysis, and Retrieval ("EDGAR") system, it contemplated that EDGAR
would include a contractor-operated, subscription-based system for disseminating filings
received by the SEC. Accordingly, when the SEC transitioned to full implementation of the
EDGAR system in 1993, dissemination was effected through a contractor-operated public
dissemination system ("PDS") paid for by subscription fees at no cost to the SEC. In September
1995, the SEC also began publishing EDGAR filings on its "" website. When the
National Securities Markets Improvement Act of 1996 directed the SEC to examine proposals
for the privatization of the EDGAR system, the SEC determined to continue disseminating
EDGAR filings to the public through both a contractor-operated PDS paid for by subscription
fees and the SEC website.

The academic study referenced in your letter suggests that EDGAR filings may
sometimes be available to PDS subscribers before such filings are available on the SEC website.
In response to that study. I directed members of my staff, in coordination with our Office of
Information Technology, to conduct a thorough assessment of the issues raised by the study and
of our dissemination process for company filings. As a result of those efforts, we are
implementing an enhancement to our system designed to ensure that EDGAR filings are
available to the public on the SEC website before such filings are made available to PDS
subscribers. Given the complex nature of the systems involved and the need for testing before
actual usage, we expect to complete this process in the first quarter of 2015. Upon
implementation, we will continue to monitor our systems to ensure optimal dissemination of
EDGAR filings to the public.

The Honorable Tim Johnson

Page 2
Thank you again for your letter. Please do not hesitate to contact me at (202) 551 -2100,
or have a member of your staff contact Tim Henseler, Director of the Office of Legislative and
Intergovernmental Affairs, at (202) 551-2010, if we can be of further assistance.

Mary Jo White

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