SEC Sets Compliance Date for New Electronic Filing Requirements on Sales of Securities

The SEC set a compliance date of April 13, 2023 by which certain financial forms (i.e., Form 144 "Notice of Proposed Sale of Securities") must be filed electronically through the EDGAR and Investment Adviser Registration Depository ("IARD") systems.

As previously covered, the amended rules require electronic filing of applications for orders under the Advisers Act, confidential treatment requests on Form 13F ("Reports of Institutional Investment Managers") filings on the EDGAR system and Form ADV-NR through the IARD system. The amended rules (i) require managers to provide their Central Registration Depository number and SEC file number (if any) and (ii) add the option to include a Financial Instrument Global Identifier in the filing for any security reported on Form 13F.