On February 12th, the SEC released a notice to N-CEN and N-PORT filers to remind them of the temporary final rule which requires funds in larger fund groups (for example, fund groups with $1 billion or more in net assets) to maintain in their records the information that is mandated to be included in Form N-PORT in lieu of filing this form via EDGAR. The temporary final rule applies until April 1, 2019. Of key importance, the information the funds in larger fund groups maintain in their records will be subject to examination by the Commission. New Forms N-PORT and N-CEN were adopted by the SEC on October 13th, 2016 in an effort to enhance transparency and modernize reporting requirements for registered investment companies.

The SEC announced on December 8th, 2017 that filing Form N-PORT on the EDGAR system will now not become mandatory until April 2019 for larger fund groups and April 2020 for smaller fund groups. However, these groups should still prepare and maintain N-PORT information in their records and make it available to the SEC upon request. This decision to modify Form N-PORT’s filing requirements comes as the agency continues its previously announced review and uplift of its EDGAR and other systems.

To aid filers avoid missing deadlines and reduce congestion around busy important filing dates, the SEC provides an anticipated peak filing schedule. Peak EDGAR filing times are estimated using historical data. The 2018 schedule is now available from the SEC.

In 2017, there were a number of new changes in EDGAR compliance and new developments in SEC regulations. These have a significant impact on financial record-keeping, financial reporting and capital formation. As we head into 2018, let’s recap some of the most significant changes that happened last year.

On December 11, 2017, EDGAR Release 17.4 was released by the Securities and Exchange Commission. This release introduces a change to allow (but not require) Asset Backed Securities filers to jointly submit Form 10-D and Form ABS-EE filings in a combined, single submission (a “Combined 10-D/ABS-EE”). New form types N-LIQUID and CERT were also added to EDGAR, among other changes.

At CFA’s Investor Forum 2017, a panel of industry experts discussed case studies that illustrate XBRL’s use in accounting and financial reporting and the rationale behind its adoption. This panel discussed different ways in which XBRL is employed in the financial sector.

The SEC is proposing amendments to modernize and simplify certain disclosures requirements in Regulation S-K. These changes are based on the recommendations made in the staff’s Report on Modernization and Simplification of Regulation S-K, as required by Section 72003 of the Fixing America’s Surface Transportation Act (FAST Act). While modernizing Regulation S-K requirements and improving readability and navigability of related forms, these rules are also intended to reduce costs and burdens on registrants and discourage repetition and disclosure of immaterial information.

The recent breach at the SEC illustrates how prevalent internet cyberattacks have become. They are a ubiquitous threat, inherent to the information exchange the internet provides. Often times with little warning or even indication that the event is occurring, hackers can infiltrate secure systems and access nonpublic information that could be exploited or damaging to multiple parties. Particularly when it comes to EDGAR, a great deal of sensitive, private information is regularly exchanged between companies and the SEC. Should this information be accessed before it’s appropriate, it could lead to all sorts of undesirable consequences. Even something as simple as prior knowledge of the type of form a company is in the process of filing can result in unwanted outcomes. Therefore, it’s essential that we as filers, filing agents, and other involved parties protect ourselves from unwanted intrusions.

On September 20th, the SEC indicated that a cybersecurity breach that occurred in 2016 may have provided the basis through which cyber threat actors achieved illicit gains. Accordingly, SEC Chairman Jay Clayton issued a statement detailing the importance of cybersecurity to the agency and market participants. The statement also reviews the SEC’s approach to cybersecurity in an effort to mitigate the risk of further incidents.

On September 11, 2017, EDGAR 17.3 was released by the Securities and Exchange Commission. This release introduces a pilot phase for the N-PORT and N-CEN EDGAR forms. Additionally, a number of forms were adjusted to allow co-registrants to designate whether they are an Emerging Growth Company.

The SEC recently released draft technical specifications for two new forms: Form N-CEN and Form N-PORT. With the upcoming release of EDGAR 17.3 (scheduled to be released September 11), these new forms will be implemented for testing.

On July 17, 2017, EDGAR 17.2 was released by the Securities and Exchange Commission. This release contained changes that added new fields to a number of forms that designate whether a registrant is an Emerging Growth Company and to inform the SEC as to whether the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards. Other changes affect a number of forms, including Form D, Form CFPortal, Form 17HACON, and the exhibit document for Form ABS-EE.

On August 1, 2017, new rules that require funds to describe their securities lending activities will go into effect.

Through Novaworks Submission Service (NSS), it’s possible to automatically schedule filings. This is an extremely handy tool to help streamline your submission process, as not only can you prepare your filing in advance, you can also have GoFiler send it to the SEC for you and notify you and your production team of the filing’s status.

In March, the SEC introduced proposed changes to include Inline XBRL Tagging in financial filings. We covered these proposed amendments in this blog post. The public comment period recently ended on May 16th, and the comments are available to read here. XBRL US offered one such comment on the proposed requirements to include Inline XBRL in financial filings, and in it expressed agreement that inclusion on Inline XBRL will help to improve the quality of reported structured financial data while reducing the burden on filers.