On September 13, Society leadership and a group of Society members met virtually with the EDGAR Business Office staff to discuss the proposed EDGAR Next modernization initiative, which would impose new multi-factor authentication requirements on EDGAR filers. The Society has submitted a comment letter that asks the SEC to extend the enrollment period to at least 12 months and take other steps to ease compliance burdens for companies and their Section 16 officers and directors.
During this meeting, Society members explained that a longer enrollment period is necessary to ensure proper coordination within companies, noting that some issuers rely on different internal teams for specific types of filings, while many companies depend on multiple third-party filing agents, law firms, and other service providers. Society members also pointed out that more time is needed for coordination among companies that share common outside directors, noting the potential for confusion and unintended mishaps if multiple corporate representatives seek to serve as the primary account administrator for the same director.
The EDGAR Business Office staff acknowledged the requests from companies and service providers for more time to prepare and said the staff is planning to conduct a robust campaign to educate filers about the new reporting regime. The staff said there will be a Help Desk to assist filers and said they would welcome the Society's input on potential FAQs and other educational materials once the EDGAR rulemaking is approved.
The Society thanks all the members who participated in this EDGAR Next meeting and provided comments on the Society's comment letter.
The SEC is scheduled to finalize this overhaul of the EDGAR system by October 2024 according to the agency's regulatory agenda.