Emerging Markets Law

SEC Temporarily Changes Rules for Form ID Filers

Coronavirus

With many businesses closed and many working from home, the Securities and Exchange Commission and its staff recognized that many applicants for EDGAR access were having difficultly getting signatures notarized on their Form ID applications.  Such notarization is required by Rule 10(b) of Regulation S-T.

In response, the SEC announced on March 26, 2019 an interim temporary final Rule 10(c) to permit applicants for EDGAR access to upload a signed copy of Form ID (completed online) without the notarization, containing a statement that applicants were unable to obtain notarization due to difficulties related to COVID-19.  In addition, within 90 days of obtaining access to EDGAR under the temporary rule, applicants must obtain notarization of the authorized signature on a copy of the completed Form ID and upload it as correspondence to their EDGAR account.  If applicants using the temporary rule do not do so, the SEC may inactivate their EDGAR access codes.

The SEC announcement indicated that it will accept applications for access that comply with the interim temporary final rule filed on or after March 26, 2020 through July 1, 2020.

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