NASPP Blog - March 10, 2009
March 10, 2009
EDGAR Passwords: One Less Thing To Do
When
I read suggestions for best practices for Section 16 reporting, I often
see keeping your insiders' EDGAR passwords current included as a
critical procedure. I disagree--I think it is a waste of time to keep
your insiders' EDGAR passwords current.
EDGAR Password: What Is It Good For?
An EDGAR password is necessary only to log onto the EDGAR filing websites, such as the EDGAR OnlineForms Management
website used for Section 16 filings. It is not included in EDGAR
filings and an insider's EDGAR password does not need to be current for
you to submit filings on his or her behalf. My guess is that your
insiders never have occasion to log onto the EDGAR filing websites; in
fact, you probably discourage them from doing this for fear they will
inadvertently mess something up.
If you have your own CIK number, the only reason you would need to
log onto the EDGAR filing websites under your insiders' CIKs would be
if you needed to update their account information. There's not a whole
lot of account information stored on EDGAR, it's mainly just the
insiders' addresses. And, since most of your insiders probably list
their work address, these addresses probably don't change that often.
Get Your Own CIK
I recommend that you have your own CIK number with your own password. This gives you access to the EDGAR OnlineForms Management website
and ensures that no one can accidentally change the password and forget
to tell you. Once you have logged onto the EDGAR OnlineForms
Management website under your own CIK, you can submit filings on behalf
of all your insiders without re-logging in under their CIKs.
It's easy to obtain your own CIK; you use the same process that you
go through to obtain EDGAR codes for a new insider, except when you
complete Form ID, you indicate that you are a "filing agent" rather
than a "filer." You simply go to the EDGAR Filer Management
website, click the link to "Apply for EDGAR Access (New)," complete the
form (be sure to specify that you are a "filing agent," not a "filer"),
print it out and have it notarized, fax the notarization to the SEC,
then wait for your CIK and passphrase. When you receive your CIK and
passphrase, go back to the EDGAR Filer Management website to generate your other EDGAR codes, including your password.
Once you have your own CIK, you can use it to log onto the EDGAR website and the only password...
more...http://www.naspp.com/blog/2009/03/something-to-take-off-your-to-do-list.html
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