Every electronic filer with the Securities and Exchange Commission ("SEC") must obtain filing codes, a CIK number, CCC number and password[fn1], before the filer may transmit an electronic filing via the SEC's electronic filing system ("EDGAR"). As a result of the Section 16 filing deadline for reporting transactions in securities on Form 4 being shortened to two days from the date of the transaction, executive officers, directors and significant shareholders are under increased pressure to electronically report their securities transactions in a timely manner. Although the process of originally obtaining EDGAR filing codes is not time consuming, it does require completion and submission to the SEC of a Form ID, which generally takes between one and three business days for the SEC to process. Once obtained the CIK (and CCC, in the case of issuers) numbers do not need to be changed; however, the filer's password must be changed annually.
When a Section 16 filer logs onto EDGAR using his or her CIK number and password (at https://www.onlineforms.edgarfiling.sec.gov/), the expiration date of the filer's password appears in red bold-faced type on the screen. Filers should calendar this date to ensure that they change their passwords prior to their expiration so their ability to make a filing will not be delayed. A filer may change his or her password within 10 days after its expiration date of the password by following the instructions on the EDGAR website. If the Section 16 filer has not changed his or her password after 10 days from the expiration date, the filer must file a Form ID to request a new password, which will delay the filer's ability to file and could lead to late filings.