The Securities and Exchange Commission is continuously seeking to enhance regulatory processes in a bid to standardize the supply-chain. Adopting XBRL was part of that process, as detailed by the Division of Economic Risk Analysis (DERA) new Associate Director, Mike Willis, who leads the DERA’s new Office of Data Science and Innovation, in an interview from 2014. With the recent updates to the EDGAR Filer Manual, it seems that focus is now on EDGAR Access.
One step in reaching reliable regulatory standards is to conform EDGAR access. With the latest update to the Form ID process, in the most recent EDGAR filer manual released March 2021, the SEC is closer to that goal.
Form ID has been amended several times since inception. April 26, 2004 saw the adoption of a new filing system, online. Prior to that effective date all EDGAR access applications had to be submitted in writing by fax, and prior to 2001 could only be submitted by mail. The online system released in 2004 was intended to benefit investors, filers and the SEC by enabling efficient transmission of Form ID with less chance of errors introduced in the processing and issuing of filing codes. Per RIN 3235-AJ09: The information needed to be transmitted in a speedy, secure and reliable manner and would directly enter the Commission’s records rather than having to be keyed in by Commission personnel.
While easing the burden of obtaining the required documents for submission of a Form ID during a pandemic, the recent amendments mean that all “new filers” now only need to submit a Form ID (with an exception for filers that are asset-backed securities issuing entities). Previously, there were two types of “new filers” seeking EDGAR access: those without any filing codes, and those who already received a Central Index Key (“CIK”) through another process but now wished to obtain filing codes. Applicants who have a CIK can no longer use the “Convert Paper Only Filer to Electronic Filer” option and must submit a Form ID with authenticating document.
The updates to EDGAR Filer Manual, Volume I include an amended rule under Regulation S-T to allow applicants for EDGAR access to use electronic notarizations and remote online notarizations for the required authenticating document. The Commission is amending the same rule to exempt the notarized document requirements for EDGAR access from certain signature requirements in another rule under Regulation S-T . This is directly related to facilitating EDGAR access during unforeseen disasters like a pandemic.
With the updated EDGAR manual, the SEC has reduced antiquated content related to that initial push to automated online form submission and moved required information to related websites. You can find technical specifications relating to the EDGAR filing process on the SEC’s web page under “EDGAR Information for Filers” and “EDGAR – How Do I.”
These changes bring the EDGAR system more in line with current technology standards while also easing into the streamlined, secure and timely transmission of regulation filings.
The Scullin Group is an EDGAR filing agency in Philadelphia, PA. We have supported clients in the region since 1991 in their Form ID and regulatory filing and printing requirements. For more information please email us at info@scullingroup.com.
