Subject: S7-12-21

Dec. 1, 2021

The following Letter Type A, or variations thereof, was submitted by individuals or entities.

RE: Potential Technical Changes to EDGAR Filer Access and Filer Account Management Processes, File Number S7-12-21

Thank you for the opportunity to comment on the potential changes to the EDGAR System with the implementation of EDGAR Next. My name is Connor Mote, I am a software developer at RDG Filings.

As you know, the majority of SEC filings are not only prepared with Filing Agent applications, they are also submitted to the EDGAR system using Filing Agent applications. It appears that the EDGAR Next updates, which improve multi-factor authentication for individuals executing DIY filings, overlook the fact that the majority of SEC filings are not submitted to EDGAR via EDGAR Online by individuals, but rather through Filing Agents and the applications they use. EDGAR Next does not appear to address this population. We encourage the Commission to consider a solution that also includes Filing Agent application authentication in addition to the Login.gov solution proposed for individuals.

Like many previous commenters, we also request that the Commission extend the deadline for the submission of comments for the potential technical changes to the EDGAR System, for the following reasons:

• November SEC Quarterly filing deadlines have limited the ability of registrants to review and respond appropriately to the Request for Comment.
• Additionally, the Thanksgiving Holiday last week further impacted registrants’ ability to conduct a thorough evaluation of the EDGAR Next program and Beta.

Most registrants do not fully understand the proposed changes to EDGAR and given the filing deadlines and holiday, we do not believe they will be able to turn their attention to the Request for Comment with a reasonable amount of time to review these proposed updates.

We respectfully ask that the Commission extend the deadline to ensure that you will be able to receive well-thought-out input from Filing Agents and Registrants. EDGAR Next will be a significant change from the current filing submission process. Receiving the appropriate feedback is critical to ensuring the efficient processing of filings as the SEC works to modernize the EDGAR process.

We appreciate your consideration, feel free to contact me with any immediate questions at file@rdgfilings.com

Respectfully,