Nov. 05, 2021
Request Info RE: Beta Testing Edgar Our firm offers compliance services to investments advisers. As such one of the services we provide is a filing agent for 13F filings. We have an internal program that files 13F’s for our clients. Therefore we are very interested in the proposed changes to the Edgar filing system. In the Beta test environment we have logged in successfully. However past that point we are unable to determine how the system will work for filing agents. Either we are not seeing the functionality in the beta site or it is not available in the beta site. Either way we have a number of questions. We originally sent our questions to EDGARNextBeta@SEC.GOV and were directed to use the commenting procedures. We operate as a filer agent for our clients for the submissions of 13F filings. We file electronically for our clients through an internally developed system. As such we need to understand how, as a filer agent, we will be able to work with our clients. We have put together the questions below. Ideally we would be appreciative of having a call with someone that we can discuss these questions with. 1. For Beta Testing will we need to use a current client to beta test them designating NCS as their filer agent? 2. Will we be able to do a test filing? Seems like the testing is just for the administrative functions such a log in, assignment of Admins/Users and potentially designation of a filer agent – Is that true? 3. As a filing agent, once we log in, are we able to submit filings on behalf of our clients as long as they have delegated us as their filer agent. Or would each individual with our firm (the filing agent) need to have their own set of credentials in order to submit a filing on behalf of each of our clients. Ideally we would still be able to file using a firm’s CIK and CCC and not have to have a separate log in for each firm we are filing for. 4. When delegating NCS as the filer agent – are they delegating US (the filing agent firm) or an individual user at our firm? 5. We are interested in the procedures for the current filing agents for their software setup? Are there additional parameters to be passed or any other specifics to be considered in order to make an automatic submission through our software applications? We appreciate your time and look forward to hearing from you. If you are willing to set up a call I can send a conference call in number so I can have my colleagues join in on the call. Thank you Jennifer Jennifer Aracri | Senior Director | FORESIDE