Please be aware that there are two significant issues that are currently affecting filers: a) issues with HTML code generated by software other than GoFiler that can result in data loss if the HTML code contains no line returns; and b) SEC changes to the EDGAR system that are affecting the filing and acceptance response time and performance. The first issue has been addressed in a hotfix for GoFiler, which you can download and install by following the instructions in this notice. The second is not a problem with GoFiler but rather a general problem with the SEC changes to the EDGAR system. More information on that is also available in this notice.

Continue reading "Notice Regarding HTML with Long Lines and..." »

The SEC’s Division of Economic and Risk Analysis (DERA) recently released its analysis of custom tag usage in financial filings submitted to the SEC. The analysis covered XBRL financial data submitted with Forms 20-F, 20-F/A, 40-F and 40-F/A from January 2017 to December 2019 by filers preparing their reports using International Financial Reporting Standards (IFRS), which is issued by the International Accounting Standards Board. The analysis focused on trends in filers’ use of custom tags in their XBRL financial data for these forms during the last three years in two categories: 1) Financial statements (F/S) only and 2) F/S and notes.
Continue reading "IFRS Trend Analysis 2019" »

The SEC has released an additional statement concerning paper filing requirements given the ongoing logistical difficulties caused by the COVID-19 pandemic. The staff of the SEC’s Division of Corporation Finance is aware of the troubles encountered in submitting certain forms (other than Forms 144) in paper given the spread of COVID-19.
Continue reading "SEC Statement Regarding Requirements for Paper..." »

The staff of the SEC’s Division of Corporation Finance states that the Division is aware of logistical difficulties of submitting Forms 144 in paper given the ongoing impact of the COVID-19 pandemic. Given ongoing health and safety concerns related to COVID-19, the staff will not recommend enforcement action if Forms 144 filed in paper under Rules 101(b)(4) or 101(c)(6) of Regulation S-T are submitted via email in lieu of mailing or delivering the paper form to the SEC if the filer or submitter attaches a complete Form 144 as a PDF attachment to an email sent to PaperForms144@SEC.gov.
Continue reading "SEC Statement Regarding Requirements for Form..." »

On June 29th, the SEC issued an order to update the filing threshold for broker-dealers’ Form 17-H filings made pursuant to Exchange Act Rules 17h-1T and Rule 17h-2T. The threshold has not been updated in nearly 30 years. In 1992, the SEC adopted the 17h Rules, which set forth specified recordkeeping and reporting requirements for certain broker-dealers that are part of a holding company structure. This was pursuant to the Market Reform Act of 1990. Broker-dealers that do not hold customer funds or securities, owe money or securities to customers, or otherwise carry the accounts of or for customers are exempt from the 17h Rules. This exemption applied provided that these broker-dealers maintain capital, including subordinated debt, of less than $20 million.
Continue reading "SEC Updates Filing Threshold to Rule 17h..." »