We’ve blogged multiple times about how you should prepare to transition to the SEC’s new “EDGAR Next” platform (here’s our latest post). We are now in that transition period where some companies are voluntarily enrolling in EDGAR Next before it becomes mandatory in September. And, as we blogged about a few months back, some companies have been forced to use EDGAR Next already, since they onboarded a new director or officer who never had EDGAR codes before (as those new insiders are required to file a Form ID under EDGAR Next).
Cooley’s Luci Altman says that many companies have been waiting to enroll insiders in EDGAR Next – perhaps in case the SEC needs to work out any kinks in the system. But those companies still need to be vigilant, because companies likely have insiders who are insiders of other companies who may have decided to already enroll those mutual insiders. If that happens, you may well be unaware that the mutual insider has been enrolled in EDGAR Next – and you will be surprised when you go to file a Form 4 for that insider, since their CCC will no longer work, as EDGAR Next enrollment automatically triggers issuance of a new CCC.
Luci reminds us that it’s important to coordinate with those companies who share insiders so that you’re not up against a Form 4 tight deadline, scrambling to ascertain their new EDGAR codes. Contact your counterparts at the companies with whom your insiders are associated to coordinate. Obtain contact information for their backups in case you have an emergency and they’re out of the office.
Perhaps the most important takeaway: You can avoid the whole “new CCC kerfuffle” by simply setting the insiders’ new CCC back to their old CCC after you have enrolled them. And don’t wait too long to get your insiders enrolled in EDGAR Next …
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