SEC Release 33-10997 introduced the following updates to filing fee disclosure and payment methods:
- affected forms are Forms S-1, S-3, S-4, S-8, S-11, F-1, F-23, F-4, and F-10 under the Securities Act and Schedules 13E-3, 13E-4F, 14A, 14C, TO, and 14D-1F under the Exchange Act, and Forms N-2, N-5, and N-14. Specifically, filers of these forms will need to file their EX-filing fee table in iXBRL by their compliance dates.
- effective January 31, 2022, filers are categorized into large accelerated filers, accelerated filers, and all other filers (including all investment companies filing Forms N-2, N-5, and N-14) and required to comply with the new structuring requirements beginning with filings submitted on or after 18, 30, and 42 months after the effective date, respectively (July 31, 2024 for large accelerated filers, July 31, 2025 for accelerated filers, and July 31, 2026 for all other filers);
- amendments to 17 CFR 202.3a, 17 CFR 230.111, 17 CFR 240.0-9, and 17 CFR 270.0-8, which are effective on May 31, 2022, have the respective extended compliance dates.
- final rule in detail can be found here.
But, what do YOU need to do now? We encourage all self-filers to participate in the SEC’s EDGAR Filing Fee Beta program, that is running from October 4, 2023 through to December 22, 2023. The SEC wants all filers to test the technical and structured data aspects of the Filing Fee Disclosure and Payment Methods Modernization Rule in preparation for the new filing structure requirements.
To participate, filers should send an email to [email protected] no later than December 8, 2023, that has the following:
- Includes the filer’s name and EDGAR Central Index Key (CIK) number; and
- Is sent from the email address that corresponds to the filer’s Contact for EDGAR Information, Inquiries and Access Code (EDGAR Contact) listed in EDGAR.
If you have any questions about where to find this contact information, reach out to let us know. We are happy to help you get situated. Call us at 215-640-3330 or email [email protected] to get in touch.
For more information on the beta program, visit this recent SEC update about it: https://www.sec.gov/edgar/beta/filing-fee-modernization
