On March 26, 2020, the SEC announced that it is providing additional relief in response to the pandemic, as follows:
- EDGAR Access Notarization Requirement: Individuals and others seeking to make their first filings on the SEC’s EDGAR system are currently required to submit notarized forms to gain access to the system. The SEC has issued a temporary final rule suspending the notarization requirement. The exemption is subject to several conditions, including that the filer submit a copy of the notarized, manually signed form within 90 days after obtaining an EDGAR account.
- Regulation A and Regulation Crowdfunding Filing Requirements: In the same temporary final rule, the SEC has extended by 45 days the deadline for certain reports and forms that companies must file under Regulation A and Regulation Crowdfunding. To qualify for the extension, a company must promptly disclose to investors that it is relying upon the extension.
If you have any questions, please contact Gunster securities law and corporate governance practice leader Bob Lamm.