Nov. 20, 2023
Dear EDGAR Next team, We note page 51 of the proposed rule where it is stated: “A user API token would remain valid for up to one year provided that the user associated with the token logged into the dashboard or one of the EDGAR filing websites at least every 30 days. If the user did not log in at least every 30 days, the user API token would be deactivated”. As a provider of Section 16 filing software, we believe this requirement will cause more frustration and annoyance than value. Users of our software have had no reason to regularly log into the EDGAR website to date. If implemented as proposed, they will at the very least be required to reset their user token annually. This annual reset is on its own, a new requirement. Requiring monthly logins to login.gov in addition to resetting user tokens annually is in our opinion, overkill. Regards, Andrew Danneffel Director Phone: (604) 609-0244 · Direct: (604) 323-4273 E-Mail: adanneffel@newsfilecorp.com Web: www.newsfilecorp.com