OT: Proposed Open Source SEC Transparency regs

For afficianados of Windows requirements in regulatory language, note there's not a single mention of "Windows" in the whole 667 pages. ;-)
http://www.sec.gov/rules/proposed/2010/33-9117.pdf
We also are proposing to require that, with some exceptions, prospectuses for public offerings of asset-backed securities and ongoing Exchange Act reports contain specified asset-level information about each of the assets in the pool. The asset-level information would be provided according to proposed standards and in a tagged data format using eXtensible Markup Language (XML). In addition, we are proposing to require, along with the prospectus filing, the filing of a computer program of the contractual cash flow provisions expressed as downloadable source code in Python, a commonly used open source interpretive programming language.
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I think that it is kind of shocking that the government would release any kind of files for the public, that would only be usable on one proprietary operating system.
i

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14:49:13 -0500, Ignoramus9512, ignoramus9512@NOSPAM.9512.invalid wrote:

That was a perhaps overly subtle dig at Unka George, who recommended in a letter to his congresscritters that Toyota PCM code should be made available to laptops running later versions of Windows. He declined to say why he wanted a Windows requirement in the regulatory language or any kind of limiting specification other than "open."
Obviously, I'm happy about a regulatory recommendation specifying open source. I'm even more pleased that they went with the relatively saner Python than the brief alternate INsane consideration, Perl. ;-)
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On Wed, 21 Apr 2010 16:09:01 -0600, Steve Ackman
<snip>

<snip> Main reason is that almost all [governmental] lap tops already have Windows installed, and while most other O/S such as Ubuntu/Linux, should work equally well, the typical computer user is not familiar with them. The main idea is box stock-off the shelf hard/software, i.e. cheap, widely available, with minimal training required. There appears to be two levels of custom programming required: (1) A simple EDR data dump and file creation so the data can be uploaded for compilation and later analysis, and (2) A more complex program to decode the EDR data dump into plain English/standard units for human understanding/analysis.
Unka George (George McDuffee) .............................. The past is a foreign country; they do things differently there. L. P. Hartley (1895-1972), British author. The Go-Between, Prologue (1953).
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17:38:57 -0500, F George McDuffee, snipped-for-privacy@mcduffee-associates.us wrote:

So... "any computer capable of interfacing with the ODB connector" would still be better regulatory language than "any laptop running a later version of Windows," wouldn't it?

Google is being extremely stupid at the moment, so I can't find said letter to Congress, but I don't recall it had to do with EDR, but rather with the program that controls the car?
Anyway, the reason for the OP in this thread was that this is the first time I've ever heard of what essentially amounts to a contract written in (an open source) computer language. It's one of those things that kind of boggles my mind at how obvious it should have been.
I think it's laudable that they specify open source, (runnable on all computers newer than say 10 years old) rather than going with something "easy" like VB, just because the majority of investors would be able to run it.
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On Thu, 22 Apr 2010 14:06:38 -0600, Steve Ackman

=======I think this is it, and indeed it referenced the vehicle control and engine management control program(s) as well as the EDR information.
The objective/rationale is to monitor OEM changes and/or updates in the vehicle control and engine management programs. When changes are detected, there should be some kind of written rationale/engineering change order/justification.
With physical items, changes such as increased size/thickness of brackets, addition of anti-drainback valves to oil filters, replacement of grade 2 fasteners with grade 8, etc. are easy to monitor but impossible to detect when the change occurs in a PROM resident computer control program.
FWIW -- I did not get even a "bug letter" response from any of my Congressional representatives.
Unka' George
On Mon, 22 Mar 2010 19:48:54 -0600, Joe Pfeiffer
<snip>

<snip> There appears to be no reason [other than inertia] that NHTSA or another agency cannot require a source code listing for computer control programs for all vehicles sold in the United States as a condition of approval for import.
This should be augmented by a copy of the "official" machine code so that the prom contents can be periodically checked against the submitted code to detect any field fixes, etc. Additionally, the EDR [event data recorder] contents and format should be standardized and the codes to download provided to agency accident investigators and law enforcement.
In order to prevent proprietary communications protocols and connections, the ability to download using a standard USP connection/cable and laptop should be required.
I sent a letter to my Congressmen on this topic on 04 March. A copy is attached. Feel free to use all, some or none of it, if you wish to write Congress.
FYI To locate your representative and to use their web mail click on http://www.house.gov/ To locate your senators and to use their web mail click on http://senate.gov/ To send an email [2.5k characters including spaces max] to the President click on http://www.whitehouse.gov/contact / Be sure to bookmark your representative's, senators' and WH web-mail sites to allow easy nagging in the future.
---- start email to congress
SUNLIGHT IS THE BEST DISINFECTANT. Justice [SCOTUS] Louis D. Brandeis (November 13, 1856 - October 5, 1941)
It is clear that Toyota continues to stonewall about providing any meaningful information about the unintended acceleration and other problems such as non-functioning brakes. http://www.msnbc.msn.com/id/35713831/ns/business-autos/
While Congress must go through the motions of politely requesting Toyota for access to the EDR [Event Data Recorder] information, it is imperative that the resources of the Federal government be used to recover not only the existing accident information, but also the actual total automotive control codes. I suggest that the NSA has a large amount of experience in such recoveries, and that the several domestic aerospace companies, which pioneered "fly by wire," as well as the FAA, have the expertise to both "reverse engineer" the Toyota automotive computer control code and run simulations to determine if unintended control sequences or paths exist, for example "wide open throttle" acceleration combined with brake inactivation as part of the anti-skid control loop.
Given the article information that 1 (one) laptop computer is located in the United States with the necessary software to download and decode/display the EDR data, I suggest the immediate enactment of legislation mandating that *ALL* EDR information must be downloadable in common ASCII format and that the software to do so must be made available to law enforcement, accident investigators, etc. using standard laptop computers running the later versions of Windows.
It is further suggested that legislation be enacted requiring all automotive manufacturers selling vehicles for use on the public roads to provide the NHTSA with not only their compiled code as burned into the PROMs, [Programmable Read-Only Memory] but also the annotated/formatted source code used to generate the compiled code, copies of the compilers/linkers/loaders used, and to provide NHTSA with not only all running changes but the reasons for the changes. This is intended to not only allow NHTSA tracking of changes in the computer control code, but also the review of the structure and origin of the source code.
It is a well-known axiom in computer science that poorly structured and "kludged" spaghetti code is never a good idea, and is the source of much trouble. Given the amount of time Toyota's problems with their vehicle control systems have persisted, and the increasing volume of problems, this has all the characteristics of a program designed by a senior manager above reproach, that was not designed correctly in the first place, and has had patch after patch after patch applied in the always futile attempt to make a silk purse out of a sow's ear. Another frequent source of this type of problem is the use of marginally qualified outside programming contractors, with excellent connections to the corporate management, possibly by blood or marriage and/or attempts by management to contain/reduce costs by having critical programming done in low wage countries.
It will also be necessary for NHTSA to perform periodic field inspections to verify that computer control program changes have not occurred. This is trivial with the correct equipment. A PROM reader is required. The PROMs are removed from the sample vehicle[s], and the code downloaded using a laptop. It is trivial to compare the downloaded PROM code with what Toyota provided NHTSA as the "current" control codes, and will require only a few minutes per PROM.
In any event the problem is not going away by itself, and will only get worse as "drive by wire" computer controls become more common. We no longer allow "secret" ingredients in the food and medicine sold to the American consumer, so why are "secret" control codes in the vehicles sold to the American consumer still allowed?
----- end email to congress
Unka George (George McDuffee) .............................. The past is a foreign country; they do things differently there. L. P. Hartley (1895-1972), British author. The Go-Between, Prologue (1953).
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18:26:26 -0500, F George McDuffee, snipped-for-privacy@mcduffee-associates.us wrote:

<snip>
So it did. My faulty memory.
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On Fri, 23 Apr 2010 10:00:07 -0600, Steve Ackman
<snip>

<snip> =======The NG may find the news item of interest.
http://news.bbc.co.uk/2/low/business/8638829.stm 23:27 GMT, Thursday, 22 April 2010 00:27 UK Brazil state bans Toyota Corolla
One of Toyota's most popular cars, the Corolla, has been banned from sale in one of Brazil's biggest states, which says the model is a safety risk.
The Minas Gerais regional government stopped sales of vehicle, claiming an acceleration problem was "putting in danger the lives of occupants". <snip> This week Toyota announced it was recalling about 34,000 Lexus GX 460 and Land Cruiser Prado SUVs worldwide.
The company said it would update the vehicles' stability-control software programme to reduce the risk of them sliding sideways when turning sharply at high speeds, partly because the fuel tank and the presence of the driver might make the left side of the vehicle heavier.
The move comes less than a week after the US consumer magazine, Consumer Reports, warned that the Lexus GX 460 was prone to roll-overs, prompting Toyota to recall nearly 10,000 sold in the US and Canada. <snip>
Unka George (George McDuffee) .............................. The past is a foreign country; they do things differently there. L. P. Hartley (1895-1972), British author. The Go-Between, Prologue (1953).
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On Fri, 23 Apr 2010 14:57:48 -0500, the infamous F. George McDuffee

Quick question. Seeing as about a third of us drive at least one of the involved Toyotas, does anyone here even know anyone who has had problems with their throttles? I don't, and nobody I've talked to does. There have been what, 3,000 of them affected (out of tens of millions of them sold) over an entire decade?

Quite like the Ford Explorer rollover fiasco, wot? I guess they have to look out for the flaky drivers who hit the brakes and swerve when they have top-heavy loads, huh? I tell ya, I'd feel safer in a GX460 than in a 7xx series BMW. I've seen two of those upside down on the freeways in LoCal...in dry weather on a slight hill/slight curve which I've taken at 100mph before in a '68 Ford Country Squire wagon, one-handed. <g> (seriously, though, I did that but it was in the opposite direction, same slight curve but slight downhill)
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On Wed, 21 Apr 2010 14:49:13 -0500, Ignoramus9512

========Actually both XML and python are cross platform languages.
http://www.go4expert.com/forums/showthread.php?tA0
http://www.python.org/download /
Unka George (George McDuffee) .............................. The past is a foreign country; they do things differently there. L. P. Hartley (1895-1972), British author. The Go-Between, Prologue (1953).
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