Mar. 23, 2023
March 23, 2023 I generally support moving to electronic filing and think the SEC should also increase its efforts at providing clear instructions on its filings and keeping its forms up to date. A simplified interface, instead of EDGAR's antiquated and confusing one would be a good start. Hover-over definitions and links to relevant rules should also be standard. Forms should also contain or link to the purpose of the form because understanding a form is key to populating it correctly, and the nature of the SEC's rules (long, prescriptive, and multiple sub paragraphs and conditions, etc.) make this an even more important feature to have. For example, FORM X-17A-5 SCHEDULE I still lists the Midwest exchange, and does not explain whether you should read that as whatever the current name that exchange may go by, or whether it is just an artifact of a form that just has not been updated. And there are many many more exchanges that are not listed at all (i.e., MEMX), so knowing why this information is elicited would help inform how to populate the form.