SEC Updates Form ID Submission Process
July 16, 2019
The SEC has updated the process to submit Form ID; here’s how it works now.
What Is Form ID?
Form ID is submitted to obtain EDGAR codes for a person or entity that needs to submit filings via EDGAR. Most readers of my blog probably use it to acquire EDGAR codes for new Section 16 insiders.
Complete Form ID in Six Steps
Here are the steps to complete Form ID under the new process:
- Go to the EDGAR Filer Management website and navigate to the Form ID. Note that between the hours of 10:01 PM to 5:59 AM Eastern Time, you can’t log onto the Filer Management website but you can still access the Form ID if you happen to have saved the URL that bypasses the Filer Management login page and goes directly to the form. (Yes, this is completely ridiculous. I can’t explain it.)
- Complete the Form ID.
- Save and print it.
- Have the printed form notarized. This is the filer’s “Authentication Document”
- Scan the notarized form to PDF, then return to the EDGAR Filer Management website, open the file you saved in step 3, and upload the scanned file. If you are doing this between 10:01 PM to 5:59 AM Eastern Time, use this link.
- Submit the completed form with the PDF of the notarized Authentication Document.
After submitting Form ID, wait for the SEC to issue the codes. See my blog on “Getting EDGAR Codes in a Hurry” if you are in rush (but try not to be in rush because the EDGAR staff gets really grumpy about this).
What’s Changed?
Well, to be honest, I’m not entirely sure because now that the new process has been implemented, there’s only limited information about what the old process was and I haven’t had to submit a Form ID in over a decade. But here are a couple of things that the SEC has noted are different about the new process.
- Theoretically, you can now save the Form ID and finish it later. I say "theoretically," however, because I have not been able to successfully do this. And I've spent several hours trying, on multiple computers. I am completely baffled as to how this is supposed to work. If anyone else has figured it out, let me know and I'll run a follow-up entry explaining it.
- The old courtesy copy of Form ID will no longer be available. Now that you can save a Form ID that you are working on (except, see #1 above), the courtesy copy is no longer needed.
What Hasn’t Changed?
The SEC’s crazy rules about characters that can/must be included in applicant and file names, as well as security protocols still apply (and are still way too complicated for me to try to summarize them). If you are having trouble, read the SEC’s FAQ on Form ID.
You also still need to check to make sure an insider doesn’t already have EDGAR codes before submitting Form ID. An insider’s assigned CIK is for life; the insider should use the same CIK (and associated EDGAR codes) for all filings, regardless of company.
- Barbara
-
By Barbara BaksaExecutive Director
NASPP