Nov. 21, 2023
Dear EDGARnext Team, I am writing to express our concerns and provide feedback on the proposed rule change regarding Section 16 filings, specifically in reference to the delegation of filing authority and the division of classifications to user groups with certain filing rights. E.P. Executive Press, Inc. doing business as CCRcorp, offers support to numerous users from various law firms who collectively manage filings on behalf of hundreds of reporting owners. We understand the SEC is trying to improve the visibility of the users of our software and who files for whom but we believe the complexities of this proposed initiative introduces complexities that may have unintended adverse effects on both filing services and the reporting owners our members represent. The proposed system's intricacy poses challenges for law firms and reporting owners alike. The delegation of filing authority and the introduction of user group classifications create a level of disruption that goes beyond mere operational adjustments. The potential for confusion and errors in compliance could have significant repercussions for all stakeholders involved. Also, having to report in a 48 hour window with additional complication is sure to lead to many late filings. In light of these concerns, we respectfully request a reconsideration and modification of the proposed rules. We believe that a more collaborative approach, taking into account the perspectives of filing services, law firms, and reporting owners, could lead to a solution that gives more visibility without being burdensome. At the very least, we request a long rollout period to not only program the necessary changes in our software but also to train users and perhaps also a grace period for users to adjust to new requirements. Thank you for considering our feedback. Linda Weber She/Her Director, Customer Success, CCRcorp 512-598-0849 | lweber@ccrcorp.com CCRcorp.com CCRcorp Publications: IMPORTANT: The contents of this email and any attachments are confidential. They are intended for the named recipient(s) only. If you have received this email by mistake, please notify the sender immediately and do not disclose the contents to anyone or make copies thereof.