By: Jen Stretch, Manager, Compliance Services at Certent
We all know that whenever previously filed exhibits are referenced in a filing, those exhibits are listed in that filing’s exhibit index. If more information is needed surrounding that exhibit, instead of simply clicking a link to point users directly to that exhibit, users must spend time manually navigating back and forth to reference exhibit information with other filings. This is a labor-intensive process and common pain point for users of the SEC’s EDGAR system as companies can have hundreds of filings and exhibits in a years’ time. Say goodbye – these days are soon behind us!
On March 1st, 2017, The SEC recently announced its Final Rule on Exhibit Hyperlinking as part of its initiative to improve ease of access to exhibit information – all but eliminating the need to search.
When the SEC originally proposed this rule in August of 2016, with the intention of continuing to modernize financial reporting, they received overwhelming support for a new hyperlinking requirement. Six months after the announcement of the Final Rule (beginning on September 1, 2017) companies that submit EDGAR filings will be required to hyperlink all exhibits listed in the exhibit index - including the exhibits that are being submitted with the filing concurrently. This applies to many common SEC form types such as registration statements, 10-Qs, 10-Ks, and 20-Fs.
There are, of course, exceptions to this rule. For one, with every filing submitted to EDGAR that includes interactive data, or XBRL, there are six files listed at the bottom of the exhibit index that start with 101. These XBRL exhibits are excluded from the hyperlink requirement. There are also other exceptions such as exhibits filed on paper and other unique cases.
Have any questions about the ruling or would like to speak with someone on the impact this will have on your filings? Post your reply below!