Subject: Comments for File Number S7-15-23
From: Andrew Danneffel
Affiliation:

Nov. 20, 2023

Dear EDGAR Next team,

The introduction of APIs to interact with EDGAR is very much welcome. Given the requirement of both a valid user and filer token to submit a filing to EDGAR via a third-party platform, I'd like to suggest an additional API be added that tests the validity of a user/filer token combination and reports back an "all clear" message or a set of issues, if any. The proposed API would check:

- If the user token is valid (exists and is not expired)
- If the filer token is valid (exists and is not expired)
- If the user token is authorized to file using the filer token

Such an API would allow users via third-party services to run a test on these two critical data points and learn of unanticipated issues in advance of time sensitive filings. Provided verbose error messages are provided, it would enable the user to easily diagnose and repair authentication issues. Third-party developers could hook up a call to this API and allow its users to test their filing authorization at any point with a button click. 

Without such an API it would appear users of third-party software would need to submit dummy test filings to ensure the tokens are in good order. That will end up being quite a few dummy test filings especially for users filing on behalf of hundreds of reporting owners satisfying Section 16 requirements.

Thank you for your consideration.

Regards,
Andrew Danneffel 
Director

Phone: (604) 609-0244 · Direct: (604) 323-4273 
E-Mail: adanneffel@newsfilecorp.com
Web: www.newsfilecorp.com